Chemical Emergency Prevention & Punning Newsletter
US EPA Region 10 	 May - June 2013
Clean Air Act 112(r) Risk Management Program (RMP)
SPCC/FRP
EPCRA
¦	Emergency Response Program
¦	24 Hour Emergency Contact
and Emergency Response
¦	Emergency Preparation Titanic
¦	Hot Work Permits
¦	NFPA704
¦	Did You Know?
CHEMICAL EMERGENCY
PREVENTION & PLANNING
Newsletter
US EPA Region 10,
OCE, OCE-084
1200 6th Avenue, Suite 900
Seattle, Washington 98101
206.553.1255
Fax: 206.553.0124
RIO RMP Webpage
Newsletter Contacts:
For RMP: Javier Morales at
morales.javier@epa.gov
For SPCC/FRP: AK: Matt Carr at
carr.matthew@epa.gov
WA OR ID: Michael Sibley at
sibley.michael@epa.gov
For EPCRA: Suzanne Powers at
powers.suzanne@epa.gov
For free Subscription:
phillips.peter@epa.gov
REPORT
<2
CHEMICAL or OIL SPILLS
to the NATIONAL RESPONSE CENTER
1-800-424-8802
Editor's Note: I'm Peter Phillips, the new editor of EPA's Region 10 Risk
Management newsletter. We all share in the responsibility of keeping our
workers, our communities, and environment healthy. My team members and
I will continue to promote and support the safety efforts in Region 10. Please
contact us if you have any questions.
-- Peter Phillips, Risk Management Program Specialist, Region 10
Emergency Response Program
The EPA Risk Management Program RMP) may require the facility that has a
Program 2 or Program 3 process (see box for details), to implement an emergency
response program, consisting of an emergency response plan, emergency response
equipment procedures, employee training, and procedures to ensure the program
is up-to-date. This requirement applies if your employees will respond to some
releases involving regulated substances.
EPA recognizes that, in some cases (particularly for retailers and other small
operations with few employees), it may not be appropriate for employees to
conduct response operations for releases of regulated substances. For example,
it would be inappropriate, and probably unsafe, for an ammonia retailer with only
one full-time employee to expect that a tank fire could be handled without the help
of the local fire department or other emergency responder. EPA does not intend to
force such facilities to develop emergency response capabilities. At the same time,
you are responsible for ensuring effective emergency response to any releases
at your facility. If your local public responders are not capable of providing such
response, you must take steps to ensure that effective response is available (e.g.,
by hiring response contractors).
Non-responding Facilities (§ 68.90(b))
EPA has adopted a policy for non-responding facilities similar to that developed by
OSHA in its Hazardous Waste Operations and Emergency Response (HAZWOPER)
Standard (29 CFR 1910.120), which allows certain facilities to develop an emergency
action plan to ensure employee safety, rather than a full-fledged emergency
response plan. Ifyouremployees will not respond toaccidental releases of regulated
substances, then you need not comply with the emergency response plan and
program requirements. Instead, you are simply required to coordinate with local
response agencies to ensure that they will be prepared to respond to an emergency
at your facility. This will help to ensure that your community has a strategy for
responding to and mitigating the threat posed by a release of a regulated substance
from your facility. To do so, you must ensure that you have set up a way to notify
emergency responders when there is need for a response.
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Coordination with iocal responders also entaiis the
following steps:
¦	If you have a covered process with a regulated toxic,
work with the local emergency planning entity to
ensure that the facility is included in the community
emergency response plan prepared under EPCRA
regarding a response to a potential release,
¦	If you have a covered process with a regulated
flammable, work with the local fire department
regarding a response to a potential release.
What Is "Response"?
EPA interprets "response" to be consistent with the
definition of response specified under OSHA's HAZWOPER
Standard. OSHA defines emergency response as "a
response effort by employees from outside the immediate
release area or by other designated responders ... to
an occurrence which results, or is likely to result, in an
uncontrolled release of a hazardous substance." The key
factor here is that responders a re designated for such tasks
by their employer. This definition excludes "responses to
incidental releases of hazardous substances where the
substance can be absorbed, neutralized, or otherwise
controlled at the time of release by employees in the
immediate release area, or by maintenance personnel"
as well as "responses to releases of hazardous substances
where there is no potential safety or health hazard (i.e.,
fire, explosion, or chemical exposure)."
However, due to the nature of the regulated substances
subject to EPA's rule, only the most minor incidents
would be included in this exception, in general, most
activities will qualify as a response due to the immediacy
of the dispersion of a toxic plume or spread of a fire, the
volatilization of a spill, and the threat to people on and off
site. As a result, if you wili have your employees involved
in any substantial way in responding to releases, you
will need to develop an emergency response program.
Your emergency response procedures need only apply to
"response" actions; other activities will be described in
your maintenance and operating procedures. Although
you do not need to describe these activities in your risk
management plan, document your efforts and keep a
record of:
¦	The emergency contact (i.e., name or
organization and number) that you will
call for a toxic or flammable release.
¦	The organization that you worked
with on response procedures.
The first responders at the scene of a release of a hazardous substance
are usually fireman or state or local police. They conduct the initial
assessment of the situation and take emergency actions such as fighting
afire, securing the area, or re-routing traffic.
Elements of an Emergency Response Program (§ 68.95)
If you will respond to releases of regulated substances
with your own employees, your emergency response
program must consist of the following elements:
¦	An emergency response plan (maintained
at the facility) that includes:
¦	Procedures for informing the public and
emergency response agencies about releases
¦	Documentation of proper first aid and
emergency medical treatment necessary
to treat human exposures
¦	Procedures and measures for emergency response
¦	Procedures for using, inspecting, testing, and
maintaining your emergency response equipment
¦	Training for ali employees in relevant procedures
¦	Procedures to review and update, as
appropriate, the emergency response plan
to reflect changes at the facility and ensure
that employees are informed of changes.
Relationship to HAZWOPER
If you choose to establish and maintain onsite emergency
response capabilities, then you will be subject to the
detailed provisions of the OSHA and EPA HAZWOPER
Standard. HAZWOPER covers preparing an emergency
response plan, employee training, medical monitoring
of employees, recordkeeping, and other issues. Call your
state or federal district OSHA office for more information
on complying with the HAZWOPER Standard (find contact
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names and addresses for OSHA offices at http://www.
osha.gov/oshdir/rlO.html/ State and local governments
in states without a delegated OSHA program are subject
to HAZWOPER under EPA's 40 CFR part 311.
How Does the Emergency Response Program Apply?
The requirements for the emergency response program
are intended to apply across all covered processes at a
facility. Although certain elements of the program (e.g.,
how to use specific items of response equipment) may
differ from one process to another, EPA does not intend
or expect you to develop a separate emergency response
program for each covered process. With this in mind, you
should realize that your emergency response program will
probably apply to your entire facility, although technically
it need only apply to covered processes. For example,
a facility may have two storage tanks, one containing
slightly more than a threshold quantity of a regulated
substance and one with slightly less. The facility is likely
to adopt the same response approach (e.g., procedures,
equipment, and training) for releases whether or not
the process is "covered." Similarly, a facility may have
two adjacent flammable storage tanks, one containing a
regulated substance above the threshold and the other
containing another, and unlisted flammable. The facility
is likely to adopt the same approach for releases whether
or not the process is "covered."
Developing an Emergency Response Program
The development of an emergency response program
should be approached systematically. The following
steps outline a systematic approach that can serve as the
framework for the program development process in each
of these cases. Following these initial steps will allow you
to conduct the rest of the process more efficiently.
1) Form an emergency response program team
The team should consist of employees with varying
degrees of emergency response responsibilities, as well
as personnel with expertise from each functional area of
your facility. You should consider including persons from
the following departments or areas:
¦	Maintenance
¦	Operations or line personnel
¦	Upper and line management
¦	Legal
¦	Fire and hazmat response
¦	Environmental, health, and safety affairs
¦	Training
¦	Security
¦	EPCRA section 302 emergency
coordinator (if one exists)
¦	Public relations
¦	Personnel
Of course, the membership of the team will need to be
more or less extensive depending on the scope of the
emergency response program. A three-member team
may be appropriate for a small facility with a couple of
process operators crosstrained as fire responders, while
a facility with its own hazmat team and environmental
affairs department may need a dozen representatives.
2)	Collect relevant facility documents
Members of the development team should collect and
review all of the following:
¦	Site plans
¦	Existing emergency response plans and procedures
¦	Submissions to the LEPC under
EPCRA sections 302 and 303
¦	Hazard evaluation and release modeling information
¦	Hazard communication and
emergency response training
¦	Emergency drill and exercise programs
¦	After-action reports and response critiques
¦	Mutual aid agreements
3)	Identify existing programs to coordinate efforts
¦	The team should identify any related
programs from the following sources:
¦	Corporate-and industry-sponsored
safety, training, and planning efforts
¦	Federal, state, and local government
safety, training, and planning efforts
4)	Determine the status of each required program
element
Using the information collected, you should assess
whether each required program element is:
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¦	In place and sufficient to meet the
requirements of RMP (part 68)
¦	In place, but not sufficient to meet the
requirements of RMP (part 68), or
¦	Not in place.
This examination will shape the nature of your efforts
to complete the emergency response program required
under the Risk Management Program. For example, if
you are already in compliance with OSHA's HAZWOPER
Standard, you have probably satisfied most, if not all, of
the requirements for an emergency response program.
Source: General Risk Management Program Guidance,
EPA 555-B-04-001, March 2009
For More Information:
Chapter 8: Emergency Response Program (PDF)
40 CFR Part 68 Emergency Response Regulations
OSHA 29 CFR 1910.38, Emergency Action Plans
OSHA 29 CFR 1910.120, Emergency Response Plans
May - June 2013
RMP Categories (Programs 1, 2 and 3)
The Risk Management Program (40 CFR 68)
defines the activities sources must undertake
to address the risks posed by regulated
substances in covered processes. To ensure that
individual processes are subject to appropriate
requirements that match their size and the risks
they may pose, EPA has classified them into three
categories ("Programs"). Program 1 requirements
apply to processes for which a worst case release,
as evaluated in the hazard assessment, would not
affect the public. These are sources or processes
that have not had an accidental release that
caused serious offsite consequences. Remotely
located sources and processes using listed
flammables are primarily those eligible for this
program. Program 2 requirements apply to less
complex operations that do not involve chemical
processing (e.g., retailers, propane users, non-
chemical manufacturers, and other processes not
regulated under OSHA's PSM Standard). Program
3 requirements apply to higher risk, complex
chemical processing operations and to processes
already subject to the OSHA PSM. The OSHA
PSM Standard (29 CFR 1910.119) reflects the
key elements that the petrochemical industry,
trade associations, and engineering societies
have deemed essential to safe management of
hazardous substances for complex, chemical-
processing operations. EPA has adopted OSHA's
PSM requirements as the Program 3 prevention
program, with only minor changes in terminology.
With few exceptions, processes assigned to
Program 3 are already subject to the OSHA PSM
Standard; the remaining Program 3 processes are
in industry sectors that have a significant accident
history.
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Chemical Emergency Prevention & Planning Newsletter
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24 Hour Emergency Contact and Emergency Response
All facilities that are required to maintain a Risk Management Plan must work with their Local Emergency Planning
Committees and other local responders to ensure that they are prepared to respond to an emergency. If your facility uses
an alarm company to contact the local responders for an emergency, what role do they play as a 24-hour emergency
contact? How would your facility emergency contact perform?
Consider the following situation.
A chlorine leak occurred in February 2007 at a bleach
production facility in Tacoma Washington. As a result of
this incident, a portion of the Port of Tacoma had to be
closed, 26 people had to be transported to area hospitals
for evaluation and treatment. The incident also required
evacuation of a number of people in the affected area.
Typically, only three employees worked the evening shift
at the bleach plant. This involved one operator working
alone in the cylinder charging area filling 7-footlong
pressurized one-ton containers with chlorine. At 6:40
p.m. the operator made an error on the fill line that
caused a release of chlorine gas. To correct his mistake
he held his breath, picked up a wrench and tried to shut
a valve. When he realized he couldn't fix the problem, he
immediately left the gas house. The operator alerted the
two other men working at the bleach plant that night,
and they also left the plant.
The chlorine release triggered an automatic alarm. The
alarm system shut the gas house doors and alerted the
facility's private alarm company. At 6:48 p.m., the 911
dispatcher answered the call from the alarm company.
The following partial transcript of the 911 call highlights
a serious flaw in the alarm system notification process
at the facility. - Insufficient Information.
Fire Department 911 Dispatcher: "What kind of alarm
is it?"
Alarm Company: "It's a fire."
911 Dispatcher: "What type of detection?"
Alarm Company: "Chlorine."
911 Dispatcher: "Chlorine? Wait a minute, it's a fire
alarm ?"
Alarm Company: "Yes."
911 Dispatcher: "OK, is it a smoke detector or a heat
detector? What's a chlorine detector?"
Alarm Company: "Umm ... it, it (stutters) just says
chlorine detector."
911 Dispatcher: "I need to know what that is. You
need to find out what that is for me, OK?"
The alarm company watch officer did not know the
difference between a chlorine alarm and a fire alarm.
Fortunately, Fire Department records showed that this
facility stored 720,000 pounds of chlorine. The confusion
over the type of alarm could have caused a delay in
notifying the responders of the need for a hazmat team.
Additionally, the Plant Manager was not allowed back
in the facility to get their notification list in his office,
which caused him to do late reporting, resulting in a
EPCRAfine.
Your Responsibility
Requirements vary according to Program Level and
responder status but all facilities must:
¦	Establish appropriate mechanism to notify
emergency responders in an emergency.
¦	Identify an emergency contact that the responder
will call for a toxic or flammable release.
continued on page 10
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Emergency Preparation - The Titanic Disaster
April 15,2012 marked the 100th anniversary of the loss of the ocean liner Titanic in the North Atlantic Ocean, approximately
2-Vz hours after hitting an iceberg. Over 1,500 people died in the most famous maritime disaster in history. Thousands
of pages have been written about the loss of the Titanic, as well as many documentary and fictional movies produced.
Many focus on the construction of the ship and the actions of its captain and crew. Whatever the construction and
operating issues, attention to one particular issue could have saved many lives - Emergency Preparation!
Some specific failures in emergency preparedness before the sinking of the Titanic included:
¦	Not enough lifeboats for all passengers and crew, perhaps because the builders considered the ship "unsinkable"!
¦	No lifeboat drills had been conducted, and many people did not know where to go or what to do.
¦	Many of the first lifeboats to leave the Titanic were not full and some occupants were
reluctant to pull other people from the icy water for fear of capsizing their lifeboat.
¦	The decision to abandon ship was
delayed while the captain and
crew assessed damage. Had the
captain started evacuation earlier,
before people began to panic,
more lifeboats may have been filled
in a more orderly evacuation.
What can you do?
¦	Process plants may conduct many
types of emergency drills. Fire, leak
or spill response, shelter-in-place,
evacuation, and severe weather
are some common types. Be aware
of your responsibility in each
situation - it may be different.
¦	In a drill or actual emergency,
watch for others who may not
remember what they should
do, especially new employees,
visitors and contractors. Help them to
¦	Promptly report any problem you observe during a drill or emergency to your supervisor. Some examples - actions
which cannot be done in the available time, things you can't do safely because of the emergency condition, exit
signs that can't be seen or are confusing, emergency alarms or speakers that can't be heard, required safety
equipment which is not available or not working properly. Report your observations - it may save a life some day.
¦	Take drills seriously and remind others that they should as well. Don't think of drills as
a time to see people from other units and let the drill become a social event.
¦	When you read about incidents in other industries, ask yourself if there is anything
you can learn from what happened to make your plant safer!
¦	Don't let your plant "sink" due to a poor emergency plan or lack of knowledge of how to respond.
Not all Process Safety lessons come from our industry!
Source: Process Safety Beacon, July 2012
respond safely.
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Hot Work Permits
Hot work permits are required for RMP Program Level 3
arid OSHA PSM regulated facilities.
The requirements are:
¦	Permit for each hot work operation
conducted on or near a covered process.
¦	The permit shall document that the fire
prevention and protection requirements in
29 CFR 1910.252(a) have been implemented
prior to beginning the hot work operations.
¦	The permit shall indicate the date(s)
authorized for hot work and the object(s)
upon which hot work is to be performed.
¦	The permits shall be kept on file until
completion of the hot work operations.
Seven Key Lessons to Prevent Worker Deaths During
Hot Work In and Around Tanks (Chemical Safety Board
Bulletin No. 2009-01-SB)
The CSB has identified over 60 fatalities since 1990 due
to explosions and fires from hot work activities on tanks.
Hot work is defined as "work involving burning, welding,
or a similar operation that is capable of initiating fires
or explosions." Hot work also includes other activities
with the potential to create a source of ignition such as
cutting, brazing, grinding, and soldering. Workers are
potentially at risk not only in the oil and gas industry,
where flammables are handled regularly, but also in
many other sectors within general industry, such as food
production, paper, and wastewater treatment.
Key Lessons from Recent Hot Work Accidents
1.	Use Alternatives - Whenever possible, avoid
hot work and consider alternative methods.
2.	Analyze the Hazards - Prior to the initiation of hot
work, perform a hazard assessment that identifies
the scope of the work, potential hazards, and
methods of hazard control. For more information
on conducting hot work hazard analyses, see
OSHA's 1910.252(a)(2)(xiv)(A) and (B);
3.	Monitor the Atmosphere - Conduct effective
gas monitoring in the work area using a
properly calibrated combustible gas detector
prior to and during hot work activities, even
in areas where a flammable atmosphere is
not anticipated. For more information about
the recommended use of a combustible gas
detector, see the Association of Energy Service
Companies (AESC) safety guidance "Hot Work."
4.	Test the Area - In work areas where flammable
liquids and gases are stored or handled, drain
and/ or purge ail equipment and piping before
hot work is conducted. When welding on or in
the vicinity of storage tanks and other containers,
properly test and if necessary continuously
monitor all surrounding tanks or adjacent
spaces (not just the tank or container being
worked on) for the presence of flammables and
eliminate potential sources of flammables.
5.	Use Written Permits - Ensure that qualified
personnel familiar with the specific site hazards
review and authorize all hot work and issue
permits specifically identifying the work to be
conducted and the required precautions.
6.	Train Thoroughly - Train personnel on hot
work policies/ procedures, proper use and
calibration of combustible gas detectors, safety
equipment, and job specific hazards and controls
in a language understood by the workforce.
7.	Supervise Contractors - Provide safety supervision
for outside contractors conducting hot work.
Inform contractors about site-specific hazards
including the presence of flammable materials.
Case Study - Food Processing Facility
Region 10, February 2009
A welding contractor was killed while repairing a VA by
Vz inch crack on the bottom of a water clarifier tank at a
food processing facility. The 23-foot-tall tank was used
to separate dirt and debris from wastewater in a potato-
washing process area. The tank was open at the top and
had a metal skirt around its cone-shaped base. While
the welder was working inside the tank, an explosion
occurred; the internal tank structures collapsed, resulting
in his death. The CSB determined that approximately 14
inches of debris-laden water had leaked through the
crack in the tank and accumulated in the hidden space
under the tank skirting. Examination of a sample of the
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liquid indicated that bacterial decomposition of the
organic matter iikely produced flammable gas, which was
then ignited by the welding activity. In this case, facility
personnel had tested for combustible gas inside the tank
prior to the hot work, but only from the entrance of the
tank and no flammable gas was detected. Monitoring for
combustible gases was not conducted in the immediate
area of the crack just priorto the initiation of the welding
or in the adjacent space where flammable gas was
present. Personnel were inadequately trained on the
use of the specific combustible gas detector that was
used and no hot work permit had been issued prior to
commencing the welding.
References and Additional Information
American Petroleum Institute (API). Safe Welding,
Cutting and Hot Work Practices in the Petroleum and
Petrochemical industries, Recommended Practice (RP)
2009, Washington, DC, 2002.
Environmental Protection Agency (EPA). Catastrophic
Failure of Storage Tanks Caused by Vapor Explosion,
Chemical Safety Alert, EPA 550-G-97-002b, May 1997.
National Fire Protection Association (NFPA). Standard for
Fire Prevention During Welding, Cutting and Other Hot
Work, NFPA51B, 2009.
NFPA. Standard for the Safeguarding of Tanks and
Containers for Entry, Cleaning, or Repair, NFPA 326, 2005.
Occupational Safety and Health Administration (OSHA).
General Requirements for Welding, Cutting, and Brazing,
29 CFR 1910.252.
Video: The Dangers of Hot Work
http://www.csb.gov/videoroom/detail.aspx?VID=44
Video: Hot Work: Hidden Hazards
http://www.csb.gov/videoroom/detail.aspx?VID=65
Cutout showing gas accumulation inside the tank skirt
Conclusion
Although the hazards of hot work are well established
and both regulatory and good-practice guidance exist,
frequent deaths and serious injuries continue to occur in
hot work-related fires and explosions. The CSB has found
that hot work is one of the most common causes of
worker deaths among accidents it investigates. Following
the seven key lessons in this bulletin - along with other
good safety practices - can prevent deaths and injuries
from hot work. In particular, host companies, contractors,
permit writers, welders, and other maintenance workers
should effectively analyze the hazards and conduct
combustible gas monitoring before and during hot work
to provide advance warning of flammable atmospheres.
Training on the proper use of such devices is imperative
for future hot work accident prevention.
Manway
- Skirt
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Know How to Identify the Hazards of Materials at your Facility and
for Emergency Response
Source: Wikipedia, the free encyclopedia
"NFPA 704: Standard System for the Identification of the Hazards of Materials for Emergency Response" is a standard
maintained by the U.S.-based National Fire Protection Association. First "tentatively adopted as a guide" in 1960,[1] and
revised several times since then, it defines the colloquial "fire diamond" used by emergency personnel to quickly and
easily identify the risks posed by hazardous materials. This helps determine what, if any, special equipment should be
used, procedures followed, or precautions taken during the initial stages of an emergency response.
Symbolism
The four divisions are typically color-coded, with blue indicating level of health hazard, red indicating flammability,
yellow (chemical) reactivity, and white containing special codes for unique hazards. Each of health, flammability and
reactivity is rated on a scale from 0 (no hazard; normal substance) to 4 (severe risk). See the latest version of NFPA 704
sections 5, 6, 7 and 8 for the specifications of each classification.
For More Information:
NFPA 704: Standard System for the Identification of the Hazards of Materials for Emergency Response, 2007 Edition.
HEALTH HAZARD
SPECIFIC HAZARD
OXIDIZtR
OXY
ACID
ACID
ALKALI
ALK
CORRQSIVL
COR
Use NO WATER
W
RADIATION
V
INSTABILITY HAZARD
Q EXTREME - Explosive at room
tempo ratu re.
SERIOUS - May detonate if shocked or
heated under confinement or mixed
with water.
MODERATE - Unstable. May react
with water.
^ SLIGHT - May react if heated or mixed
with water.
Q MINIMAL - Normally stable.
Does not react with water.
FLAMMABILITY HAZARD
Q EXTREME - H ghly toxic - May be fata1
on short-term exposure.
0 SERIOUS - Toxic - Tiill protective suit
and breathing apparatus should be worn.
MODERATE - Breathing appcntuR
and face mask must oe worn.
SLIGHT - Breatining apparatus may
be worn.
Q SLIGHT-Slightlycombustible.
Requires strong heating to ignite-
MINIMAL - Will not burn under
normal conditions.
0 MINIMAL - Mo precautions
necessary.
MODERATE - Corv :5iis:ihle.
Requires moderate heating to ignite,
flash Point beiow 200T.
0 SERIOUS - Flammable.
Flash Point 73°F to 100°F.
Q EXTREME - Extremely flammable gas
or liquid. Rash Point below 73nF,
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Lessons Learned
Insure your emergency contact receives training and has all the necessary
information needed in case of an incident.
¦	Knows what each alarm indicates.
¦	Presence of toxics and/or flammables.
¦	Can communicate this information to the appropriate
emergency response organization; e.g., "911."
¦	Facility staff should carry a notification list with them. Remember
that during an emergency, office records may not be accessible.
Be Prepared Before Things Can Go Wrong
Remember to evaluate your emergency response program before a
chemical release occurs.
Sources: EPA Newsletter, July - August 2009
Did You Know?
The five most common violations of Risk Management Program in EPA Region 10
(WA, OR, ID, AK), regardless of chemical or industry, are:
Process Hazard Analysis § 68.67 (e): The owner or operator shall establish a
system to promptly address the team's findings and recommendations; assure
that the recommendations are resolved in a timely manner and that the
resolution is documented; document what actions are to be taken; complete
actions as soon as possible; develop a written schedule of when these actions are
to be completed; communicate the actions to operating, maintenance and other
employees whose work assignments are in the process and who may be affected
by the recommendations or actions.
Management § 68.15 (a): The owner or operator of a stationary source with
processes subject to Program 2 or Program 3 shall develop a management system
to oversee the implementation of the risk management program elements.
Documentation § 68.39 :The owner or operator shall maintain the following
records on the offsite consequence analyses for the worst-case scenarios,
alternative release scenarios, estimated quantity release rate, duration of release,
estimated population and environmental receptors potentially affected.
Updates § 68.190 (a): The owner or operator shall review and update the RMP as
specified in paragraph (b) of this section and submit it in the method and format
to the central point specified by EPA as of the date of submission.
Operating procedures § 68.69 (a): The owner or operator shall develop and
implement written operating procedures that provide clear instructions for safely
conducting activities involved in each covered process consistent with the process
safety information and shall address at least the following elements, in paragraphs
(a)(1) to (a)(4).
Where Do I Go For More Information?
RMP Materials EPA's Web site: http://
www.epa.gov/emergencies/content/rmp/
index.ntm includes tne kisk Management
program rule, Off-Site Consequence Analysis
specific guidance and calculator, the list of
regulated substances, fact sheets, guidance
documents, industry-specific model plans,
FAQs, the RMP*eSubmit Users' Manual, and
other information.
EPA RMP Region 10
RMP Coordinator: Javier Morales 206-553-
1255
EPA Region 10 RMP Website: http://yosemite.
epa.gov/R10/airpage.nsf/EnTorcement/rmp
Superfund, TRI, EPCRA, RMP & Oil
Information Center - The information
center can also answer questions related
to Clean Air Act Section 112(r) and RMP
reporting requirements. Contact the RCRA,
Superfund, and EPCRA Call Center for your
policy, regulatory compliance, and reporting
requirements questions.
800-424-9346 Toll Free or TDD 800-553-7672
Monday - Thursday: 10:00 AM - 3:00 PM
Eastern Time Extended Hours of Operation
(May, June and July): Monday - Friday: 9:00
AM - 5:00 PM Eastern Time (Closed Federal
Holidays) http://www.epa.gov/superfund/
contacts/infocenter/
RMP*eSubmit Software Support Contact the
RMP Reporting Center for specific software
questions about RMP*eSubmit. (703)
227-7650 (phone) Monday - Friday: 8:00
a.m. - 4:30 PM ET. Closed Federal Holidays
RMPRC@epacdx.net (e-mail)
LISTSERVS EPA maintains numerous listservs
to keep the public, state and local officials,
and industry up to date, including several
that pertain to emergency management.
You can sign up for our listserve to receive
periodic updates:https://lists.epa.gov/read/
all_forums/subscriDei'name=caiicenter_
oswer
This newsletter provides information
on the EPA Risk Management Program,
EPCRA, SPCC/FRP and other issues
relating to Accidental Release Prevention
Requirements. The articles contained herein
are provided for general purposes only. EPA
does not accept responsibility for any errors
or omissions or results of any actions based
upon this information. Please consult the
applicable regulations when determining
compliance. Mention of trade names,
products, or services does not convey, and
should not be interpreted as conveying
official EPA approval, endorsement, or
recommendation. The information should
be used as a reference tool, not as a
definitive source of compliance information.
Compliance regulations are published in
40 CFR Part 68 for CAA Section 112(r) Risk
Management Program, 40 CFR Part 355/370
for EPCRA, and 40 CFR Part 112.2 for SPCC/
FRP.
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